Every week brings a new gold token: one token, one gram or one ounce of gold, tradable around the clock, sent anywhere in minutes. The pitch is always about the token. The blockchain, the app, the speed.
The real question with tokenised gold is not the token. It is the bar. Where is it? Who holds it? And can you get it out? A token is only as good as the bar behind it, and the bar is only as good as the place it sits. That is why, when clients ask me where to build a gold token, my answer is Switzerland.
Four questions about the bar
Where is it? In which vault, in which country, insured by whom, and audited how often? “Stored in a secure vault” is not an answer. The name of the vault operator, the country and the date of the last bar-by-bar audit are.
Who holds it, and in whose name? This is the question that decides what happens on a bad day. With allocated gold, specific bars, with their own serial numbers, are set aside and kept apart from the custodian’s own assets. With unallocated gold, you only have a claim against the custodian for a quantity of metal. If the custodian fails, allocated bars can be claimed back, while unallocated metal leaves you in the queue of creditors. But allocated to whom? Bars allocated in the name of the token issuer are not the same as bars on which the token holders have rights of their own, and a serial number on a list does not, by itself, prove that you own the bar. Ask the concrete question: if the issuer disappears, can I go to the vault directly and get my gold, with which documents, and at what cost?
Can you get it out? Redemption is where many gold tokens disappoint. With PAX Gold, for example, physical delivery starts at 430 tokens, one full London Good Delivery bar of about 400 ounces, plus fees. Since no bar weighs exactly 430 ounces, the tokens above the actual weight of the bar delivered are credited back to the holder’s account, less fees. I explained this in Real Estate Tokenisation: What Can I Do With a Token That I Couldn’t Do Without One? The small holder really owns his share of a bar, but he cannot take it home. Ask before you buy: what is the minimum, what does delivery cost, where can the bar be collected, and in what size?
Do the bars and the tokens match? Counting the bars is not enough. An audit must reconcile them with every token in circulation: was the metal received and allocated before the tokens were issued, are tokens cancelled or blocked when gold is delivered, has any of the metal been pledged or lent, and what exactly does the insurance cover? And one more thing: a token you can transfer at 3 a.m. does not guarantee you a buyer at 3 a.m., a price close to the gold price, or a bar in your hands the next day.
Why Switzerland has an edge few places can match
The token has a clear legal status. Since 2021, Swiss law has recognised ledger-based securities, rights recorded on a blockchain that can be transferred only through that blockchain (article 973d of the Code of Obligations). The same reform allows a document of title to goods, such as a warehouse receipt for gold held in a vault, to take that form (article 1153a). In plain words: in Switzerland, a properly structured token can be the legal title to the bar, not just a marketing promise that someone, somewhere, holds gold for you.
The vaults sit in a stable country. Switzerland has a long tradition of safekeeping, a predictable legal system and a political stability that most gold-storage locations cannot offer. When the asset is meant to protect you from crises, the place it sits matters as much as the asset itself. There is also plain geography. A vault in the Gulf sits within range of Iranian missiles, as the strike on a base in Qatar in June 2025 reminded everyone. A vault under the Alps does not.
The refineries are next door. Four of the world’s largest gold refineries are Swiss: Argor-Heraeus, Valcambi and PAMP in Ticino, and Metalor in Neuchâtel. Industry sources estimate that Swiss refiners process a large share of the world’s gold. For a token issuer, this means the gold behind the token can be bought straight from the refinery, with a documented origin, and recast there if needed, for example to turn a 400-ounce bar into kilo bars or smaller bars that token holders can actually collect.
Investment gold is free of VAT, and the rest can sit under bond. In Switzerland, investment gold, meaning bars of at least 995 fineness bearing the stamp of a recognised refiner, and granules sealed by one, is exempt from VAT, both when it is sold and when it is imported, and so is gold sent for refining or recovery. There is no customs duty either: Switzerland abolished its duties on industrial goods in 2024. The exemption covers the metal, not the services around it: storage, platform and delivery fees are taxed normally. Silver, platinum and palladium are subject to Swiss VAT, but they can be kept in a customs warehouse, such as a free port, where import VAT is suspended for as long as the metal stays under bond.
Put all this together and you get something rare: a token with a legal status, a bar in a stable country with no VAT on it, and a refinery a few hours’ drive away that can turn the token back into metal.
Three ways to run a gold business in Switzerland
What most people miss is that you do not need a token to run a modern gold business in Switzerland. The legal framework already lets you build it in three stages, and you can stop at any of them.
Stage one: the warehouse receipt. The Code of Obligations has provided for it for more than a century. A warehouse keeper who publicly offers to store goods can obtain from the competent authority the right to issue documents of title for the goods it holds (article 482). That document, the warehouse receipt, represents the gold itself: handing it over transfers the gold, without the bar ever leaving the vault (articles 1153 to 1155, and article 925 of the Civil Code). A buyer and a seller can trade a bar sitting in a Swiss vault with a piece of paper. No blockchain, no token, and the law has been tested for generations. One caution: a simple storage certificate from any vault is not a document of title. The warehouse keeper needs that authorisation.
Stage two: the same receipt, with a QR code. Add a QR code to the warehouse receipt, linked to the warehouse keeper’s own register, and anyone can check in seconds that the receipt matches what the warehouse keeper has recorded. It is still a paper document of title, under the same rules. The QR code is only as reliable as the register behind it: how often it is updated, who audits it independently, and how receipts are transferred and cancelled. With a well-kept register, it makes the oldest frauds in the trade, the forged receipt and the same bar sold twice, much harder.
Stage three: the token. If you want the gold to move like a digital asset, divided into small units and transferred around the clock, you can go one step further. Since 2021, the document of title itself can take the form of a ledger-based security (article 1153a), so the token can carry the same legal effect as the paper receipt: whoever holds it holds the right to the gold. Not every gold token is built this way. Some give the holder co-ownership of the gold, others only a contractual claim against the issuer, and these three constructions do not give the same rights. Read the terms before you read the white paper.
Each stage adds speed and reach, and each adds cost and regulatory questions. Many clients will make money at stage one or two. Tokenise when your customers need it, not because the word sells.
Swiss VASP: the SRO route for a gold token
Now the part founders usually ask about last, and should ask about first: which licence?
In Switzerland, trading precious metals for clients is a form of financial intermediation under the Anti-Money Laundering Act. So is transferring or holding crypto assets for clients. A gold token business that sells, transfers or holds tokens for its customers is therefore a financial intermediary, a Swiss VASP (virtual asset service provider) in international language, and must be affiliated with a self-regulatory organisation, an SRO, recognised by FINMA. The SRO checks its anti-money laundering procedures, its people and its annual audit.
For many gold token models, the SRO route is the right door: faster and lighter than a FINMA licence. Be clear about what it covers: SRO affiliation is supervision for anti-money laundering, not a prudential licence from FINMA, and each bank will still run its own checks. Before relying on it, make sure the model does not need a FINMA licence on top. There is a line not to cross, and it runs through the bar:
- Allocated gold, held for the clients and kept apart from the issuer’s assets, can keep the business on the SRO route, if the rest of the structure holds.
- Unallocated gold, or client money pooled to buy metal on the issuer’s account, starts to look like taking deposits from the public, which generally requires a banking licence.
- Depending on how it is structured, the token itself may qualify as a security or even a collective investment scheme, with their own rules.
Every structure has to be checked: the regime depends on the rights the holder gets, how the token is transferred, how the gold is held and what the company actually does. For a new model, it is often worth asking FINMA for a ruling before launching. A good structure is one where the custody contract, the token terms and the licence all tell the same story.
One more point on timing. As of November 2026, the Swiss government has proposed new licences for payment instrument institutions and crypto institutions. The consultation closed in February 2026 and the reform is still going through the legislative process: nothing changes until it is adopted and in force. Until then, the SRO is the fastest regulated door into the Swiss market, and the one that works today.
How FintechLex can help
We help gold dealers, fintechs and investors build gold tokens in Switzerland, from the bar to the blockchain:
- structuring the token and its legal terms, so that the holder’s rights over the bar are clear;
- setting up the custody chain: allocated custody agreement, vault, insurance, audits and the link with a Swiss refinery;
- SRO affiliation for the issuing company, or a ready-made company already affiliated with an SRO, after checking that it fits your project and preparing the changes of shareholders, management and business model;
- checking the line between the SRO route and a FINMA licence, and preparing a ruling request when it is worth it;
- opening the banking relationships a gold token needs.
If you want to move fast, we also offer a turnkey SRO on a shelf company, ready to carry a Swiss VASP activity. And if the vocabulary of tokens is new to your team, our Stablecoin Glossary explains the terms that matter, from redemption to custody.
Write to us at insight@fintechlex.com or on WhatsApp +41 787 983 770.
Rene-Philippe
Sources: Swiss Code of Obligations, article 482 (warehouse keepers authorised to issue documents of title), articles 1153 to 1155 (documents of title to goods), articles 973d to 973i (ledger-based securities) and 1153a (documents of title as ledger-based securities), in force since 2021 (DLT Act); Swiss Civil Code, article 925; Federal Act on Value Added Tax, article 23 paragraph 2 number 12 and article 53 paragraph 1 letter m (gold, as revised on 1 January 2025); Federal Council, abolition of industrial tariffs (in force 1 January 2024); Anti-Money Laundering Act, article 2 (financial intermediaries); FINMA, guidelines on initial coin offerings; Federal Council, consultation on the amendment of the Financial Institutions Act (22 October 2025 to 6 February 2026); Paxos, PAX Gold terms and conditions, section 11.4 (physical redemption); BullionStar, The Swiss gold market (refinery data).
This article is for general information only and does not constitute legal advice. Every gold token structure must be assessed on its own facts.
